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Latest Articles


Essential Financial Steps and Tax Tips that every NRI’s must not miss

Finance : Discover essential financial steps and tax tips for NRIs, including converting accounts, trading restrictions, and leveraging DTAA...

July 18, 2024 717 Views 0 comment Print

Taxation in Digital Economy: Income Tax provisions in India vis-à-vis Permanent Establishment

Income Tax : Explore India's income tax provisions for the digital economy, focusing on the concept of Permanent Establishment and recent legal...

July 13, 2024 660 Views 0 comment Print

Interpretation of Phrase “May be taxed” used in Paragraph 3 of Article 23 of India- UK DTAA, 1993

Income Tax : Explore the purpose of Double Taxation Avoidance Agreements (DTAA) and their interpretation, along with landmark judgments shaping...

June 7, 2024 882 Views 0 comment Print

Taxation for NRIs

Income Tax : Understanding taxation for NRIs: Learn about residential status, taxable income, deductions, and the importance of Double Taxation...

April 19, 2024 6678 Views 0 comment Print

Tax Avoidance and Inequality: Connecting the Dots in India

Income Tax : Explore the nexus between tax avoidance and inequality in India. Learn how legal loopholes deepen economic divides and discover st...

April 19, 2024 483 Views 0 comment Print


Latest News


Representation to Simplify & Automate TRC Issue Process for Indian Companies

Income Tax : Explore challenges in TRC applications under DTAA by Indian companies. KSCAA proposes reforms for a simpler, efficient process. Le...

June 22, 2024 234 Views 0 comment Print

India-Cyprus Double Tax Treaty: Benefits, Tax Recovery & Golden Passport

Income Tax : Explore the details of India's Double Tax Treaty with Cyprus, its signing date, benefits for both nations, tax recovery provisions...

December 11, 2023 759 Views 0 comment Print

Need for amendment of DTAA to stop double taxation of Indian IT firms

Income Tax : Need for early amendment of DTAA regulations to stop the double taxation of Indian IT firms: Ms. Anupriya Patel tells the visiting...

July 24, 2022 816 Views 0 comment Print

Cabinet approves Agreement with Saint Vincent for Tax Information exchange

Income Tax : The Union Cabinet, chaired by the Prime Minister Shri Narendra Modi has approved anAgreement between the Republic of India and Sa...

June 23, 2021 717 Views 0 comment Print

CBDT releases MLI synthesised text for India-Czechoslovak Socialist Republic tax treaty

Income Tax : CBDT has released the synthesised text for India-Slovak Republic tax treaty. It represents their shared understanding of the modif...

March 19, 2020 390 Views 0 comment Print


Latest Judiciary


Condition of ‘make available’ not satisfied hence technical service not taxable: ITAT Delhi

Income Tax : ITAT Delhi held that the condition of make available was not satisfied for services when provided by assessee did not enabled the ...

August 16, 2024 72 Views 0 comment Print

Domestic company paying DDT u/s. 115O doesn’t enter domain of DTAA: ITAT Pune

Income Tax : ITAT Pune held that the DTAA does not get triggered at all when a domestic company pays DDT u/s. 115O of the Income Tax Act. In nu...

August 16, 2024 78 Views 0 comment Print

Reassessment unsustained as based on entirely new reason which deprives assessee’s right to object: Delhi HC

Income Tax : Delhi High Court held that initiation of reassessment based on entirely new or previously undisclosed material or reasoning depriv...

August 12, 2024 192 Views 0 comment Print

No tax on amount paid for certification services rendered by foreign entities in absence of fixed place of business in India

Income Tax : Understand the Ahmedabad ITAT ruling that payments for certification services by foreign entities are not taxable in India without...

August 1, 2024 162 Views 0 comment Print

Additional grounds raised in appeal needs adjudication by lower authority: ITAT Chennai

Income Tax : ITAT Chennai restored the matter back to the file of AO for re-adjudication as additional ground raised by the assessee in appeal ...

July 26, 2024 654 Views 0 comment Print


Latest Notifications


CBDT Amends India-Spain Double Taxation Avoidance Agreement (DTAA)

Income Tax : Explore the Notification No. 33/2024 on the agreement between India and Spain for tax exchange. Understand its implications and ch...

March 19, 2024 2238 Views 0 comment Print

CBDT notifies Tax Information Exchange Agreement: India-Samoa

Income Tax : Explore implications of Notification No. 21/2024 from Indias Ministry of Finance regarding the tax information exchange pact with ...

February 7, 2024 867 Views 0 comment Print

Income Tax Agreement Between India & Saint Vincent for information Exchange

Income Tax : Notification No. 96/2023-Income Tax: Learn about the agreement between India and Saint Vincent for tax information exchange and as...

November 1, 2023 609 Views 0 comment Print

DTAA between India and Chile notified by CBDT

Income Tax : Notification No. 24/2023- Income-Tax Dated: 03rd May, 2023 under section 90(1) of Income tax Act, 1961 regarding Agreement and Pro...

May 3, 2023 2403 Views 0 comment Print

Clarification on Most-Favoured-Nation clause in Protocol to India’s DTAAs

Income Tax : The Central Board of Direct Taxes (CBDT) has received representations seeking clarity on the applicability of the MFN clause (part...

February 3, 2022 4248 Views 0 comment Print


Sports Broadcasting Fees for Live Feed Not Taxable as Royalty: Delhi High Court

January 21, 2024 639 Views 0 comment Print

Delhi High Court’s judgment in CIT vs. Fox Network Group Singapore PTE Ltd. clarifies income tax treatment of live transmission fees under Income Tax Act Section 9(1)(vi).

Significant Economic Presence (SEP): Implications for Non-Residents in India

January 20, 2024 1761 Views 0 comment Print

This article sheds light on the concept of Significant Economic Presence (SEP) under Section 9 of the Indian Income Tax Act, 1961, and its implications for non-residents.

Section 115-O Rate Applies for Additional Tax on Dividends to Non-Residents, Not DTAA Rate

January 19, 2024 840 Views 0 comment Print

Explore Sennheiser Electronics India vs Circle – 4 case at ITAT Delhi. Section 115-O rate applies for additional tax on dividends to non-residents, not DTAA rate.

Royalty u/s 9(1)(vi): Broadcasting rights for live event not chargeable to tax as royalty

January 18, 2024 1011 Views 0 comment Print

ITAT Delhi held that broadcasting “Live events” does not amount to a work in which copyright subsists i.e., “Live Rights”, is not “copyright” and therefore any payment made thereto can’t be said to be chargeable to tax as royalty under section 9(1)(vi).

Avoidance of Double Taxation agreement

January 17, 2024 1368 Views 0 comment Print

Explore the impact of Double Taxation on international business, the role of Double Taxation Avoidance Agreements (DTAA), benefits, and case laws. Learn how to apply DTAA for tax relief

Software Sale Payment Not Royalty under Indo-Singapore DTAA: Delhi HC

January 17, 2024 585 Views 0 comment Print

Delhi High Court upholds ITAT order: Payments received for software sale/supply not considered royalty under India-Singapore Double Taxation Avoidance Agreement (DTAA).

Section 248 Inapplicable to Tax Liability in Dividend Distribution by a Company

January 16, 2024 684 Views 0 comment Print

Explore the Madras High Court’s ruling on Section 248’s inapplicability to dividend declarations. Detailed analysis and implications of the judgment.

Delhi High Court Closes CCD Taxation Appeals, Awaits Supreme Court’s Final Decision

January 16, 2024 693 Views 0 comment Print

Delhi High Court disposes of CIT Vs Zaheer Mauritius appeals, addressing taxability and capital gains nature of Compulsorily Convertible Debentures under India-Mauritius DTAA.

BEPS Principles and MLI Framework in India’s PE Status under DTAA

January 15, 2024 1143 Views 0 comment Print

Explore the impact of BEPS principles and MLI framework on India’s Double Taxation Avoidance Agreements (DTAA). Detailed analysis of the India-Singapore DTAA, changes in PE clauses, and post-BEPS amendments.

Receipt in terms of Strategic Oversight Services Agreement cannot be termed as royalty

January 6, 2024 528 Views 0 comment Print

Delhi High Court held that the consideration received in terms of Strategic Oversight Services Agreements (SOSA) cannot be termed as Royalty under Article 12 of the DTAA even if extensive services are rendered which includes access to written knowledge, processes, and commercial information in furtherance of the services.

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